PMLA ECIR continuity and linked FIRs can survive a closure summary where connected offences share the same proceeds of crime.

The PMLA scheme requires a scheduled offence and proceeds of crime as the jurisdictional basis for action, and an ECIR remains dependent on that predicate foundation. The document states that, where later FIRs arise from the same banking fraud ecosystem, modus operandi and chain of proceeds, they may be subsumed within an already existing ECIR as part of the same transaction and investigation. Acceptance of C-summary in the original FIR does not, by itself, extinguish the ECIR if other connected scheduled offences have already been brought into the same investigative fold. On those facts, the challenge to the ECIR and inclusion of the later FIRs failed.

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Issues: Whether, after acceptance of a C-summary in the original predicate offence, the Enforcement Case Information Report could survive and continue to absorb subsequently registered connected FIRs; and whether the later FIRs could validly be treated as part of the same money-laundering investigation.

Analysis: The statutory scheme under the Prevention of Money Laundering Act, 2002 makes the existence of a scheduled offence and the existence of proceeds of crime the jurisdictional foundation for action under the Act. The Court noted that an ECIR is an internal document and that money laundering is an independent offence, but it remains dependent on a live predicate offence and a causal nexus with proceeds of crime. On the facts, the original ECIR was founded on the first FIR, which alleged a scheduled offence under the Indian Penal Code, 1860. The subsequent FIRs arose from the same banking fraud ecosystem, the same modus operandi, and the same common chain of proceeds. The Court found a proximate and causal link between the first ECIR and the later FIRs, and held that the later FIRs were capable of being included within the already subsisting ECIR as part of the same transaction and investigation. The acceptance of C-summary in the first FIR did not, by itself, extinguish the ECIR where other connected scheduled offences had already been brought within the same investigative fold.

Conclusion: The challenge to the ECIR and to the subsumption of the subsequent FIRs failed; the ECIR was held to survive, and the inclusion of the later FIRs was upheld.

Ratio Decidendi: Where connected scheduled offences sharing the same criminal design and proceeds of crime are shown to have a proximate causal link with an existing ECIR, later FIRs may be brought within the same ECIR notwithstanding acceptance of a closure summary in the original FIR.

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